• Drafted oppositions to emergency motion for certification of interlocutory appeal pursuant to 28 U.S.C. Section 1292(b) and emergency petition to stay non-jury trial and writ of mandamus filed with the Third Circuit Court of Appeals.
  • Successfully defeated motion to remand and drafted successful motion for leave to file joint amended notice of removal. Roberts v. Glens Falls Ins. Co, 415 F. Supp.2d 779 (N.D. Ohio 2006).
  • Drafted motion for summary judgment regarding coverage under a Securities Broker/Dealer’s Professional Liability policy, asserting that coverage was precluded because the claim was not first made and reported during the policy period, and that the policy’s prior wrongful acts and profit or advantage exclusions precluded coverage.
  • Interviewed and retained engineering, boiler and machinery, and coverage experts for litigation involving bodily injury and property damage coverage for boiler explosion.
  • Assisted in the research and writing of successful post-trial motion that remitted $4 million jury verdict to $2 million.
  • Defended declaratory judgment and equitable contribution claims made by co-insurer. Responsibility for written discovery; depositions of insured, insured’s defense counsel for underlying asbestos claims, and co-insurer’s claim representatives; and preparation of dispositive motion on issues of late notice and doctrine of unclean hands.
  • Drafted motion to dismiss wrongful death claims made against insured hospital by surviving family members based upon the policy’s bodily injury exclusion.
  • Assisted with research and writing of successful motion to quash appeal. Koresko Financial, L.P. v. Capital Financial, 953 A.2d 847, 2008 Pa. Super. LEXIS 1483 (Pa. Super. April 11, 2008) (decision without published opinion).
  • Defended declaratory judgment and bad faith action made by insured. Responsible for written discovery; depositions of insured, insured’s in-house counsel responsible for settlement of underlying copyright infringement claim; and preparation of dispositive motion on issue of advertising injury.
  • Prepared direct and cross-examination outlines for trial testimony of wrongful death, coverage, and bad faith trial resulting from insured state constable association member’s automobile accident.
  • Interviewed and retained fate and transport and dry cleaning operations experts for litigation involving long-tail perchloroethylene pollution.
  • Drafted successful motion for relief from judgment pursuant to Civ. R. 60(B) and briefing on affirmed appeal. Spicer v. Ace Prop. & Cas. Ins. Co., 2004 Ohio 6756, 2004 Ohio App. LEXIS 6810 (Ohio Ct. App. Dec. 9, 2004).
  • Drafted successful motion for summary judgment and appellate briefs regarding retroactive application of Ohio Supreme Court decisions and law of the case doctrine. Lewis v. Kizer, 2004 Ohio 3551, 2004 Ohio App. LEXIS 3203 (Ohio Ct. App. July 6, 2004).
  • Drafted motion for summary judgment arguing that accidental death benefits were not available for drug overdose because employee did not sustain “bodily injury caused by an accident,” resulting “independently of all other causes” and that coverage was precluded by the policy’s “intentionally self-inflicted injury” and “sickness, disease” exclusions.
  • Drafted motion for summary judgment regarding coverage for fatal motorcycle accident of insured’s employee under business auto, general liability, and umbrella policies.
  • Analyzed underlying claims and litigation files in order to prepare for depositions of insurance broker, insurer’s underwriter and claims handlers, and insured’s general counsel, risk manager, claims counsel, and claims personnel.
  • Drafted motion to disqualify trial counsel, motions in limine, and outlines for trial testimony in coverage dispute over first party property coverage.